As stablecoins become an increasingly important component of the financial system, the GENIUS ACT is defining how payment stablecoins are issued, regulated, and supervised in the United States. Understanding this evolving framework is critical for banks, fintechs, and other market participants navigating the digital assets landscape.
In its latest Quarterly Report, the Conference on Consumer Finance Law published a new article by Chapman senior counsel Judy Chen–with support from Finance Law Development Program analyst Emily Callahan–examining the comprehensive federal framework for payment stablecoins under the GENIUS Act. The article provides a practical overview of stablecoins and their key use cases, examines the legislative history behind the GENIUS Act, and analyzes the Act’s core requirements—including issuer eligibility, reserve and disclosure obligations, AML compliance, and bankruptcy treatment. Judy also explores the risks and regulatory uncertainties that remain as agencies undertake extensive rulemaking required by the statute–notably including the regulations laid out in the Office of the Comptroller of the Currency’s recent Notice of Proposed Rulemaking, which Chapman explored in our recent Client Alert here.
This article is reprinted with permission.
